What is CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora authority for?

An assessee cannot be burdened with additions based solely on the statement or material obtained from a third person, especially when no satisfaction under section 153C has been recorded against the third person, and the assessee has not been granted an opportunity to cross-examine the third person.

How many judgments cite CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora?

78 judgments on BharatTax cite CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora (396 ITR 644), spanning 2018 to 2025.

Which sections of the Income Tax Act does CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora come up under?

It is most often cited in judgments turning on Section 127, Section 132(4), Section 132(4A), Section 143(2), Section 143(3), Section 153A.

CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora (396 ITR 644)

JOINT COMMISSIONER OF INCOME TAX (OSD), CENTRAL CIRCLE-20, DELHI vs. M B POWER (MADHYA PRADESH) LTD., DELHI

In the result, appeal of the Revenue is dismissed

ITA 267/DEL/2024[2021-22]Status: DisposedITAT Delhi19 Dec 2025AY 2021-22

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…e statement of a third person. Such a course would lead to demand in case of any and every assessee. It is for this reason that Delhi High Court in CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora (2018) 402 ITR 175 and CIT v. Radico Khaitan Ltd (2017) 396 ITR 644 have deleted the additions. F. The excel files seized from Mr. Rajiv Saxena do not constitute material pertaining to the assessee, for no satisfaction u/s 153C was recorded by the AO of Mr. Saxena. His statement cannot be relied upon, for no opportunity to cross examine him was granted. G. The stand of the assessee on the alleged pay-back by LANC…

MB POWER (MADHYA PRADESH) LIMITED,DELHI vs. DCIT, CENTRAL CIRCLE-20, DELHI

In the result, appeal of the Revenue is dismissed

ITA 211/DEL/2024[2021-22]Status: DisposedITAT Delhi19 Dec 2025AY 2021-22

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…e statement of a third person. Such a course would lead to demand in case of any and every assessee. It is for this reason that Delhi High Court in CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora (2018) 402 ITR 175 and CIT v. Radico Khaitan Ltd (2017) 396 ITR 644 have deleted the additions. F. The excel files seized from Mr. Rajiv Saxena do not constitute material pertaining to the assessee, for no satisfaction u/s 153C was recorded by the AO of Mr. Saxena. His statement cannot be relied upon, for no opportunity to cross examine him was granted. G. The stand of the assessee on the alleged pay-back by LANC…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI vs. MB POWER (MADHYA PRADESH) LIMITED, DELHI

In the result, appeal of the Revenue is dismissed

ITA 3923/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…e statement of a third person. Such a course would lead to demand in case of any and every assessee. It is for this reason that Delhi High Court in CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora (2018) 402 ITR 175 and CIT v. Radico Khaitan Ltd (2017) 396 ITR 644 have deleted the additions. F. The excel files seized from Mr. Rajiv Saxena do not constitute material pertaining to the assessee, for no satisfaction u/s 153C was recorded by the AO of Mr. Saxena. His statement cannot be relied upon, for no opportunity to cross examine him was granted. G. The stand of the assessee on the alleged pay-back by LANC…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-20, DELHI vs. M. B. POWER (MADHAYA PRADESH) LTD, DELHI

In the result, appeal of the Revenue is dismissed

ITA 3874/DEL/2023[2016-17]Status: DisposedITAT Delhi19 Dec 2025AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…e statement of a third person. Such a course would lead to demand in case of any and every assessee. It is for this reason that Delhi High Court in CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora (2018) 402 ITR 175 and CIT v. Radico Khaitan Ltd (2017) 396 ITR 644 have deleted the additions. F. The excel files seized from Mr. Rajiv Saxena do not constitute material pertaining to the assessee, for no satisfaction u/s 153C was recorded by the AO of Mr. Saxena. His statement cannot be relied upon, for no opportunity to cross examine him was granted. G. The stand of the assessee on the alleged pay-back by LANC…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 20, DELHI vs. M.B. POWER (MADHAYA PRADESH) LTD, DELHI

In the result, appeal of the Revenue is dismissed

ITA 3870/DEL/2023[2017-18]Status: DisposedITAT Delhi19 Dec 2025AY 2017-18

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…e statement of a third person. Such a course would lead to demand in case of any and every assessee. It is for this reason that Delhi High Court in CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora (2018) 402 ITR 175 and CIT v. Radico Khaitan Ltd (2017) 396 ITR 644 have deleted the additions. F. The excel files seized from Mr. Rajiv Saxena do not constitute material pertaining to the assessee, for no satisfaction u/s 153C was recorded by the AO of Mr. Saxena. His statement cannot be relied upon, for no opportunity to cross examine him was granted. G. The stand of the assessee on the alleged pay-back by LANC…

MB POWER (MADHYA PRADESH) LIMITED ,SOUTH EAST DELHI vs. DCIT, CENTRAL CIRCLE-20, DELHI, DELHI

In the result, appeal of the Revenue is dismissed

ITA 3850/DEL/2023[2018-19]Status: DisposedITAT Delhi19 Dec 2025AY 2018-19

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…e statement of a third person. Such a course would lead to demand in case of any and every assessee. It is for this reason that Delhi High Court in CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora (2018) 402 ITR 175 and CIT v. Radico Khaitan Ltd (2017) 396 ITR 644 have deleted the additions. F. The excel files seized from Mr. Rajiv Saxena do not constitute material pertaining to the assessee, for no satisfaction u/s 153C was recorded by the AO of Mr. Saxena. His statement cannot be relied upon, for no opportunity to cross examine him was granted. G. The stand of the assessee on the alleged pay-back by LANC…

DCIT, GHAZIABAD vs. M/S. DEVIDAYAL ALUMINIUM INDUSTRIES PVT. LTD., GHAZIABAD

In the result, appeal of the Revenue is dismissed

ITA 3850/DEL/2016[2007-08]Status: DisposedITAT Delhi08 Jan 2025AY 2007-08

Bench: Shri Sudhir Kumar & Shri Manish Agarwal[Assessment Year : 2018-19] M.B.Power (Madhya Pradesh) Vs Dcit, Ltd., 239, Okhla Industrial Central Circle-2, Estate, Nehru Place, Gurgaon Delhi -110019. Pan-Aafcm6698A Appellant Respondent

Section 132(4)Section 143(2)Section 153CSection 250

…e statement of a third person. Such a course would lead to demand in case of any and every assessee. It is for this reason that Delhi High Court in CIT v. Sant Lal (2020) 423 ITR 1, Pr. CIT v. Manoj Hora (2018) 402 ITR 175 and CIT v. Radico Khaitan Ltd (2017) 396 ITR 644 have deleted the additions. F. The excel files seized from Mr. Rajiv Saxena do not constitute material pertaining to the assessee, for no satisfaction u/s 153C was recorded by the AO of Mr. Saxena. His statement cannot be relied upon, for no opportunity to cross examine him was granted. G. The stand of the assessee on the alleged pay-back by LANC…

NISH DEVELOPERS PVT. LTD.,MUMBAI vs. DCIT- CC- 6(3), MUMBAI

In the result, all the appeals of the assessee except ITA

ITA 3131/MUM/2018[2010-11]Status: DisposedITAT Mumbai12 Mar 2021AY 2010-11

Bench: Shri Rajesh Kumar & Shri Ram Lal Negi

For Appellant: Shri Rakesh Joshi, A.RFor Respondent: Shri P.C. Chhotaray

Section 132(4)

…e relied upon while M/s. Nish Developers framing assessment in the case of appellant. In defence of his arguments and averments, the ld AR placed reliance on the following decisions:- • ITO Vs W D Estate P Ltd ( 45 ITD 473)(Mum) • CIT Vs. RadicoKhaitan Ltd ( 396 ITR 644)(Delhi) • ACIT Vs. DrRanjanPai (109 Taxmann.com 90)(Banglore) He further submitted that during cross examination before AO during assessment proceeding, the employee Mr Pravin Mishra confessed that he has prepared all these data on his own imagination. Therefore, considering the facts of the case and judicial pronouncement in this regard, it is…

NISH DEVELOPERS PVT. LTD.,MUMBAI vs. DCIT - CC -6(3), MUMBAI

In the result, all the appeals of the assessee except ITA

ITA 3129/MUM/2018[2011-12]Status: DisposedITAT Mumbai12 Mar 2021AY 2011-12

Bench: Shri Rajesh Kumar & Shri Ram Lal Negi

For Appellant: Shri Rakesh Joshi, A.RFor Respondent: Shri P.C. Chhotaray

Section 132(4)

…e relied upon while M/s. Nish Developers framing assessment in the case of appellant. In defence of his arguments and averments, the ld AR placed reliance on the following decisions:- • ITO Vs W D Estate P Ltd ( 45 ITD 473)(Mum) • CIT Vs. RadicoKhaitan Ltd ( 396 ITR 644)(Delhi) • ACIT Vs. DrRanjanPai (109 Taxmann.com 90)(Banglore) He further submitted that during cross examination before AO during assessment proceeding, the employee Mr Pravin Mishra confessed that he has prepared all these data on his own imagination. Therefore, considering the facts of the case and judicial pronouncement in this regard, it is…